The proposed TLD string is "web."
Image Online Design has been operating the.web registry for the
past four years. The registry to date has received substantialworldwide
support from the Internet community and is widely regarded as
a desirablenew TLD string.

The .web registry will be operated in an
open and competitive fashion. Specifically, the registry will
compete directly with .com, .net, .org and any new TLD. Registrants
will be allowed to register second level domain names within the
.webregistry without any additional hierarchical structure.

Initially, all registrations will be processed
by the registry operator. Soon afterentering the root, all domain
name registrations will be processed through ICANNaccredited registrars.
Image Online Design will divest its registrar operations, forming
aseparate company (Image Online Design Registrar Company) facilitating
completecompetition for .web registrations. Similar to the process
used by Network Solutions,Image Online Design may require an initial
test period which will include a number oftest bed registrars
to ensure technical stability. The respective roles, functions,
andresponsibilities for the registry operator and registrars will
closely follow the current .comworking model. As all registrars
will be ICANN accredited registrars, it is expected thatImage
Online Design Registrar Company will seek ICANN accreditation.

E5.1. What measures will be taken to discourage
registration of domain namesthat infringe intellectual property
rights?

Image Online Design recognizes the longstanding
and legitimate concernswith regard to trademark violations on
the Internet. We are committed toprotecting intellectual property
rights of trademarks holders. Accordingly, wehave adopted ICANN's
Uniform Dispute Resolution Policy to ensure trademarksare afforded
the proper protection. Additionally, we propose to give trademarkholders
preemptive rights to challenge existing .web registrations. Once
.web isaccepted by ICANN as a new TLD, this process would allow
trademark holders,during a phase in period, to place existing
.web registrations on hold pending theresolution of a dispute
under either the Uniform Dispute Policy or filed with acourt of
competent jurisdiction. Lastly, during a phase in period, we intend
tooffer a free one-for-one exchange of any .web registration currently
held by aregistrant for any other available .web name. It is our
aim that this one-for-oneexchange will encourage those registrants
who may have registered a domainname which infringes upon rights
of another to exchange that domain name forone which does not.
The exchange program will be offered until the 14 dayblackout
period prior to entering the root. See E5.3 below. Taken as a
whole, webelieve these policies will substantially reduce trademark
violations in the .WebTLD.

E5.2. If you are proposing pre-screening
for potentially infringing registrations,how will the pre-screening
be performed?

No pre-screening of registrations for potential
infringement will takeplace. Any pre-screening process would require
Image Online Design to evaluatethe strength or merits of a trademark
and domain name. We are not qualified norhave authority to make
such an evaluation. Therefore, we will defer suchevaluations to
courts of law or similar administrative bodies or panels. Thepublicly
accessible look-up system (whois) currently in use offers sufficientsearch
capabilities for trademark holders to monitor the registration
database forpotential infringement of trademarks. The operation
of the look-up system isdetailed in section E5.6 below.

E5.3. What registration practices will be
employed to minimize abusiveregistrations?

In addition to the measures discussed in
E.5.1 and E.5.2, the registry willcease taking new registrations
during a 14 day blackout period prior to enteringthe root. This
blackout period will enable trademark holders to scan domainnames
currently registered for any potential infringement and to bring
anappropriate action to remedy that infringement. This policy
will be aggressivelypublicized to allow trademark holders sufficient
opportunity to police theirtrademarks during the blackout period.

Additionally, at no time will Image Online
Design allow anyone to registera domain name without the payment
of the registration fee. For customers withestablished credit
with Image Online Design, payment may be made within alimited
amount of time, but must be paid. For customers without establishedcredit
with Image Online Design, payment must be made at or before the
time ofthe domain name registration. This policy will prevent
persons from stockpilingnumerous domain names without payment
of registration fees, only to re-registerthe same domain names
when an arbitrary payment deadline expires, againwithout payment
of registration fees.

E5.4. What measures do you propose to comply
with applicable trademark andanti-cybersquatting legislation?

Image Online Design is in full compliance
with all United States lawpertinent to trademark and anti-cybersquatting
issues. Additionally, Image OnlineDesign will comply with orders
from courts of competent jurisdiction andarbitration decisions
issued under the UDRP.

E5.5. Are you proposing any special protections
(other than during the start-upperiod) for famous trademarks?

No. Much like pre-screening for potentially
infringing registrations (seeE5.2), affording any special protection
to famous trademarks would require ImageOnline Design to evaluate
the strength of those marks. Accordingly, becauseImage Online
Design is not qualified nor does it have authority to make such
anevaluation, we defer such evaluations to courts of law or similar
administrativebodies or panels. The publicly accessible look-up
system (WHOIS) currently inuse offers sufficient search capabilities
for trademark holders to monitor theregistration database for
potential infringement of trademarks. The operation ofthe look-up
system is detailed in section E5.6 below.

E5.6. How will complete, up-to-date, reliable,
and conveniently provided Whoisdata be maintained, updated, and
accessed concerning registrations in the TLD?

Complete data on all registrations, registrants
and DNS zone information is contained in the .Web Registry database,
and is made available both via a web-based form and a traditional
port-43 whois interface. Both interfaces retrieve theirdata directly
from the registry database so as to provide up-to-the-minuteinformation.

E6.2. Please describe any additional, alternative,
or supplemental disputeresolution procedures you are proposing.

Image Online Design is committed to improving
the UDRP to ensure aproper balance between property rights and
user's rights. To that end, we willactively participate in industry
working groups addressing this pressing issue.

Complete data on all registrations, registrants
and DNS zone information iscontained in the .Web Registry database,
and is made available both via a web-basedform and a traditional
port-43 whois interface.

E8. Billing and Collection.
Describe variations in or additions to the policies for billing
andcollection.

As indicated above, at no time will Image
Online Design allow anyone to registera domain name without the
payment of the registration fee. For customers withestablished
credit with Image Online Design, payment may be made within a
limitedamount of time, but must be paid. For customers without
established credit with ImageOnline Design, payment must be made
at or before the time of the domain nameregistration. This policy
will prevent persons from stockpiling numerous domain nameswithout
payment of registration fees, only to re-register the same domain
names when anarbitrary payment deadline expires, again without
payment of registration fees.

E9. Services and Pricing.
What registration services do you propose to establish charges
for and,for each such service, how much do you propose to charge?

Registration of second-level domain names
in the .Web zone will be charged $15per name, per year at the
registry, and an additional $20 per name, per year at theregistrar,
for a total of $35 per name, per year. It is also anticipated
that additionalservices such as DNS record hosting, web hosting,
email forwarding, and other servicesthat have been developed in
our proof-of-concept and which will be developed in thefuture
will be offered at pricing to be determined.

II. REGISTRATION POLICIES
DURING THE START-UP PERIOD (Required for all TLDs)

E11. In this section,
you should thoroughly describe all policies (including implementationdetails)
that you propose to follow during the start-up phase of registrations
in the TLD, to theextent they differ from the General TLD Policies
covered in items E1-E9. The followingquestions highlight some
of the areas that should be considered for start-up policies:

Responsive answers are provided to the specific
questions which follow.

E12. How do you propose
to address the potential rush for registration at the initial
opening ofthe TLD? How many requested registrations do you project
will be received by the registryoperator within the first day,
week, month, and quarter? What period do you believe should beconsidered
the TLD's "start-up period," during which special procedures
should apply?

Image Online Design has taken great steps
to ensure our systems will be capableof providing adequate capacity
to handle such an initial rush for registrations. Specifically,
section D15.2.10 ("Peak Capacities") details our ability
to process up to 2million registrations per day. Our initial registration
projections are detailed in section D13.2.2 and D13.3_A page F-63.
Specifically we anticipate over 853,000 newregistrations during
the first quarter of operation. Our systems have been designed
toprocess more than that each day!

E14. Will pricing mechanisms
be used to dampen a rush for registration at the initial opening
ofthe TLD? If so, please describe these mechanisms in detail.

No pricing mechanism will be used to dampen
a rush or registration. A set fee,currently $35 per year, will
be charged for each domain name registered. Image OnlineDesign
feels that increasing the initial cost of registrations is less
desirable than providingadequate capacity to handle the rush for
registrations at the initial opening of the TLD. Increasing the
initial cost of registrations creates, in effect, a Dutch auction
for domainnames, which gives an unjustified advantage to wealthier
entities in obtaining the mostdesirable registrations. At the
same time, such a system results in a windfall for theregistry
and registrar unwilling to invest adequate resources to adequately
handle theinitial rush for registrations.

E15. Will you offer any
"sunrise period" in which certain potential registrants
are offered theopportunity to register before registration is
open to the general public? If so, to whom will thisopportunity
be offered (those with famous marks, registered trademarks, second-level
domains inother TLDs, pre-registrations of some sort, etc.)? How
will you implement this?

The inherent difficulty in giving priority
to owners of trademarks is that it is afundamental premise of
trademark law throughout the world that different entities areallowed
to use the identical mark so long as there is not likelihood of
consumer confusionbetween the two uses. For example, there are
scores of entities that use the markUNITED, or variations thereon,
on a variety of different goods and services withoutconfusion
to consumers. This includes United Van Lines and United Airlines
whoseUNITED mark is arguably one of the more famous marks in the
world. Thus, justbecause an entity owns a registered trademark
does not mean that they have exclusiverights to use that mark
as a domain name. In fact, even an entity that has a famous markoften
does not have exclusive rights to any use of that mark. Additionally,
in manyjurisdictions, owners of unregistered trademarks ("common
law trademark rights") mayhave rights that are superior to
registered trademark rights and even the rights in famousmarks.

Thus, there is no simple formula or criteria
that would identify one class ofentities or individuals that should
always have priority over another class of entities orindividuals.
Rather, every mark owner's particular rights in a particular mark
would haveto be evaluated individually in order to properly protect
every trademark owner's rights. This evaluation is something that
only a judicial or quasi-judicial body has the authorityand qualifications
to make.

With respect to entities already holding
second level domains in other TLDs, theyshould not be given superior
rights in new TLDs, absent a judicially or quasi-judiciallydetermination
regarding the applicability of their trademark rights to the second
leveldomain in the new TLD. One of the primary purposes in opening
up new TLDs is torelieve some of the pressure caused by a very
limited number of present TLDs in whichdifferent entities can
register the same second level domain name. If existing secondlevel
domain name holders were given priority in registering identical
second leveldomain names in new TLDs, it would effectively eliminate
the fundamental benefit to theInternet community in adding new
TLDs.

On the other hand, entities that have already
registered .web second level domainnames with Image Online Design
are in a different situation. Unlike many applicants tobe included
as new ICANN TLD registries, Image Online Design has not been
accepting"pre-registration" for domain names, but rather
has been accepting registrations in anoperating domain name registry.
Although the number of Internet users connected todomain name
servers that are presently able to resolve Image Online Design
.Webdomain names is small relative to the total number of Internet
users, this number is stillreal and significant. Accordingly,
Image Online Design will follow the same basic policywith respect
to existing Image Online Design .Web domain name registrations
that hasbeen in effect in the domain name system from the beginning,
namely, first-come, first-serve.

Notwithstanding the difficulties in providing
generic sunrise provisions forparticular classes of trademark
owners, though, Image Online Design will implement apolicy that
will provide significant protection to trademark owners during
the fullinclusion of .Web domain names into the main DNS system.
First, if any trademarkregistration owner files a UDRP complaint
or file suit to contest the ownership of adomain name registration
in a court of competent jurisdiction before .Web is added to theroot,
Image Online Design will place the subject .Web domain name registration
on hold,preventing use of that domain name by anyone. This remedy
is not presently available totrademark owners in the .com, .net
and .org TLDs. This remedy will allow trademarkowners to block
widespread potential trademark infringement through the use of
apreviously registered Image Online Design .Web second level domain
name registrationbefore it is allowed to begin. Additionally,
Image Online Design will provide a notice ofthis policy to all
existing Image Online Design .Web domain name registrants andencourage
them to voluntarily relinquish any domain names that are likely
to provoke adomain name dispute and register a different domain
name in its place without charge. This offer will be revoked,
however, should a domain name be formally contested, eitherthrough
the filing of a complaint under the UDRP or the filing of a legal
action in a courtof competent jurisdiction with respect to the
domain name. See section E5.1 above.

E22. This section is intended
to allow you to describe the benefits of the TLD and the reasonswhy
it would benefit the global Internet community or some segment
of that community. Issuesyou might consider addressing include:

E23. What will distinguish
the TLD from existing or other proposed TLDs? How will thisdistinction
be beneficial?

.Web's world-wide appeal is evident in light
of our approximately 20,000registrations from over 95 countries.
See Appendix D13.2.2_B and D13.2.2_C.
.Web isfree from potentially limiting associations with a type
of activity, as in the case of .net or.org (i.e., network providers
or non-profits) or geographic associations, as in the case of.com
(which is perceived as United States centric) or country codes
which are alwaysperceived centric to that particular country.

E24. What community and/or
market will be served or targeted by this TLD? To what extent
isthat community or market already served by the DNS?

The .Web registry will service the worldwide
Internet community. Additionally,unlike all currently existing
TLDs, .Web is not representative of a particular geographicarea
or function; such as the implied commercial nature of .com. .Web
is unique in itsdirect association with the medium of the worldwide
web, and shares the worldwideweb's international reach and value-neutral
implications.

E25. Please describe in
detail how your proposal would enable the DNS to meet presently
unmetneeds.

.Web will be a direct competitor to .com
and open for all markets and uses byInternet users. This will
greatly serve the community as the availability of .com names
isgreatly reduced due to over registration. Currently available
TLDs such as .com, .net and.org are perceived as U.S. centric
and do not meet the need for a TLD that is free fromgeographic
and functional associations; a need that .Web directly addresses.

E26. How would the introduction
of the TLD enhance the utility of the DNS for Internet users?For
the community served by the TLD?

The introduction of .Web will increase the
number of attractive second-leveldomains available to be registered,
thereby increasing the utility of the DNS as a whole.Since the
DNS was invented as a mnemonic device to allow Internet users
to easilyremember locations (as opposed to having to remember
and use IP numbers), theintroduction of new TLDs increases this
utility. .Web in particular is an attractive TLDthat will particularly
serve this purpose.

E28. Recent experience
in the introduction of new TLDs is limited in some respects. The
currentprogram of establishing new TLDs is intended to allow evaluation
of possible additions andenhancements to the DNS and possible
methods of implementing them. Stated differently, thecurrent program
is intended to serve as a "proof of concept" for ways
in which the DNS mightevolve in the longer term. This section
of the application is designed to gather informationregarding
what specific concept(s) could be evaluated if the proposed TLD
is introduced, howyou propose the evaluation should be done, and
what information would be learned that might beinstructive in
the long-term management of the DNS. Well-considered and articulated
responsesto this section will be positively viewed in the selection
process. Matters you should discuss inthis section include:

Responsive answers are provided to the specific
questions which follow.

E29. What concepts are
likely to be proved/disproved by evaluation of the introduction
of thisTLD in the manner you propose?

The most important concept to be proved
by evaluation of the introduction of the.Web TLD and others is
that adding additional TLDs will not adversely affect theoperation
of the existing Internet domain name resolution system. Other
concepts to beproved include: high quality domain name registry
and registrar services may be providedeffectively by private,
for-profit organizations under a free market system, domain nameregistry
services need not be "owned by the Internet community"
or otherwise be highlyand tightly regulated, Internet users will
accept and use .Web domain names, both inusing the world wide
web and in other Internet usages.

E31. In what way would
the results of the evaluation assist in the long-range management
of theDNS?

The primary manner in which the results
of the evaluation of new the operationTLDs, including .Web will
benefit the long range management of the DNS is in provingthe
numerous important benefits to the Internet community in adding
new TLDs. Whilecareful oversight of the operation of new registries
and registrars by ICANN is needed inorder to assure the smooth,
safe operation of the Internet, free-market competition is themost
effective way to provide the most utilitarian Internet while providing
the bestservice to the Internet community in the most economically
efficient manner. Theintroduction of more TLDs will simply increase
the utility of the Internet and provideeven greater competition
with corresponding greater service and better pricing for theInternet
community.

E32. Are there any reasons
other than evaluation of the introduction process that this particularTLD
should be included in the initial introduction?

Image Online Design has been running a .Web
domain name registry for over fouryears and has registered nearly
20,000 domain name names from 95 countries. Thequality and extent
of Image Online Design's experience in this regard is second in
theworld, only to Network Solutions. This experience will insure
the highest degree ofsuccess, particularly with respect to the
important criteria of: Absence of negativeimpacts on the existing
Internet domain name resolution system; Stability and smoothtechnical
operation of the registry; and Satisfaction by domain name registrants
in thecustomer service received from the Registrar(s) and Registry.

By signing this application through its
representative, the Applicant attests that the informationcontained
in this Description of TLD Policies, and all referenced supporting
documents, are trueand accurate to the best of Applicant's knowledge.